Finding 1144659 (2024-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
$1
Year
2024
Accepted
2025-06-27

AI Summary

  • Core Issue: NWIFC failed to document procurement processes and verify vendor eligibility, risking compliance with federal standards.
  • Impacted Requirements: Non-compliance with 2 CFR sections 200.318-200.326 and 180.220 regarding procurement and suspension/debarment checks.
  • Recommended Follow-Up: Ensure adherence to documented procurement policies and maintain necessary documentation for all transactions.

Finding Text

Program Information: U.S. Department of the Interior Single Agreement – Assistance Listing #15.036 Award Number: A18AV00341 Award Period: 10/01/2023 – 9/30/2024 Criteria: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Per 2 CFR § 200.303 Internal controls, the non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the Federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/Context: 1 of 3 procurement samples selected for testing had no documentation of bidding, alternative price quotes, or sole source documentation. Additionally, for 1 of 1 Individually Important Items and 2 of 2 suspension and debarment samples selected for testing, NWIFC could not provide support showing a SAM.gov check was performed prior to conducting business with the vendors. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: It appears the policies and procedures for procurement and suspension and debarment were not followed. Effect: Without solicitation from an adequate number of qualified sources, NWIFC is at risk of over-spending on projects and, thus, leaving fewer resources available to fulfill the mission of NWIFC. Additionally, NWIFC could be subject to other sanctions from funding agencies if they determine that programs did not assure vendors were properly checked for suspension and debarment. Questioned Costs: $25,750 for procurement. This amount represents procurement transactions selected for testing that lacked required documentation of competitive bidding, price comparisons, or sole source justifications. As a result, these costs do not meet the allowability and procurement standards under 2 CFR 200.318–200.320 and are therefore questioned. Not applicable for suspension and debarment. While internal controls were not followed, no specific transactions were identified that violated the cost allowability requirements. Repeat Finding: Yes, finding #2023-003. Recommendation: We recommend that the NWIFC adhere to program policies and procedures as documented and supporting documentation is kept available for review. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 568217 2024-002
    Material Weakness Repeat
  • 568218 2024-003
    Significant Deficiency
  • 1144660 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
15.036 Single Agreement $8.52M
66.121 Psp Epa Fy19-21 Implementation $3.05M
66.121 Psp Epa Fy22-24 Implementation $2.28M
66.121 Psp Epa Capacity $592,301
11.438 Coastal Salmon Recovery $550,676
11.437 Noaa Hatchery Genetic Mgmt $328,316
66.926 General Assistance Program $308,052
66.121 Psp Epa Fy16-18 Implementation $135,385
11.438 Hatchery Reform-Nwifc $89,128
66.608 Twqd/wqx 3.0 Schema $48,750
10.025 Usda Emer Response Training $47,329
15.608 Treaty Indian Catch Monitoring $25,409